Examination of Witnesses (Questions 400
- 409)
TUESDAY 2 JULY 2002
MR MIKE
GILBERT, MR
RICHARD BOARDER
AND MR
ROBERT DAVIES
Paddy Tipping
400. You have talked, Mr Gilbert, about the
Substitute Fuels Protocol and how it is out of date, but clearly
you have got to regulate what you burn; if you are not happy with
the present situation, what is the better way of doing it?
(Mr Gilbert) The Substitute Fuels Protocol, as we
said, is a supplementary regulation, behind regulations, that
was established in the 1990s. The regulations it supplemented
and supported have now changed, we now have IPPC regulation, we
have the Waste Incineration Directive, we have now a new agreement
on stakeholder dialogue with the Tyres Protocol. So we believe
it is now time to review and overhaul that, too, we just think
that it provides, if you like, a break on our ability to move
forward to improved environmental performance options. And, as
I say, one of the characteristics of it is that, even when we
have established that we are putting in place an improved environmental
performance, say, by burning tyres, we have to stop burning tyres
while we go through a consultation process with the Agency, and
then we go back to burning tyres once they have approved it. So
we just believe it is time to review that.
401. I just thought I would ask you if there
is an experimental period where you measured the discharges?
(Mr Gilbert) We try to demonstrate that what we are
doing is correct.
(Mr Davies) If I can give you some case history. The
context in which the Substitute Fuels Protocol was established
is a decade old, and significant additional regulation has been
put in place since that period; we now have IPPC, we now have
the Waste Incineration Directive, and, as an industry, we have
signed up to a significantly enhanced level of stakeholder dialogue.
So the context in which the original SFP was put in place, I think,
is dated, and we have moved on from there, and it is our proposition
really that the SFP is redundant. If I can give a case example,
if we were to apply for an alternative fuel permit on a cement
kiln in the UK, from the date of the first application through
to the date of the permit being authorised, typically, it takes
17 to 20 months. Similar cement kilns in western Europe, whether
it is France or in the Benelux countries, are less than six months;
and, hence, in western Europe, we see levels of waste utilised
in the cement industry of 40 to 50 per cent, and there are significant
levels of high temperature incineration active in those countries,
and yet in the UK we have two active incinerators and an average
of 6 per cent waste utilised in the cement industry. If you look
at the European average of waste utilised in the cement industry,
it is 12 per cent, and it is only 12 per cent because the UK is
holding the average down, and if it were based on best practice,
which is France and the Benelux countries, it would be closer
to 40 per cent.
402. So we have talked a lot this morning about
how EU regulations drive this; why is it different in Germany,
why is there not a common Protocol across the EU about what you
can burn?
(Mr Gilbert) The regulations are common,
I think it is the interpretation, and certainly, if you like,
the attitude of Governments towards where waste streams go and
the industry as a whole. The example that comes to mind is in
Belgium. Because I sit on a European Forum, where I share information
with trade bodies like mine right across Europe, we go round the
table, from time to time, and we find out what is happening; and,
of course, when the Belgians had their problems with MBM and infected
chicken-meal, they went to the cement industry, they co-opted
a cement kiln and they burned the lot. That does not happen here;
we have offered the opportunity to discuss those things, with
MBM and chicken-meal, and any other kind of issues, but this Government's
attitude at the moment is that they do not really feel ready to
do that. What we were trying to do, today, by coming to this Committee,
was to say, we really do believe we are an opportunity, a waste
solution, and it is an opportunity for us perhaps just to change
the paradigm, if you like, of what we can do and what we are not
able to do.
403. Yes, but one of the issues that Dick Boarder
raised was that you have got to be good to your neighbours, and
what comes out of the stack, the emissions, is very important
to people who live close by; and this has been quite controversial,
and, for example, if you were buying bone-meal, one could imagine
that the local populace would be concerned about this. And another
issue is around high temperature incineration, because I do not
understand the science, but, as I understand what comes out of
the stack, many fewer dioxins come out of the stack in high temperature
incineration than come out of your plants?
(Mr Gilbert) You will hear, in a minute,
about what actually happens in a kiln, but we do burn at extremely
high temperatures, and also we have what is called a long dwell
time, which means basically that the waste material spends much
longer at high temperatures in the kiln. And the other thing that
you will hear happens is that we break down the chemicals significantly,
there are not wastes, you do not get ash coming out of a cement
kiln, as you might do with an incinerator. But, rather than hear
it from me, you should hear it from Rob.
(Mr Davies) It does sound like a perfect opportunity,
really, Mr Chairman, to invite the Select Committee to visit a
cement factory.
404. We are going to produce this report before
then; you had better make your pitch now, I think?
(Mr Davies) You are very welcome to attend
one of our factories, whether it is in the UK or in western Europe,
so you can get a better understanding of what the true potential
of a cement kiln would be, in terms of disposal of waste. The
public is very concerned about what goes on within a cement factory
and what comes out of the chimney. Over the last decade, we have
significantly enhanced our stakeholder dialogue, we hold exhibitions
on a regular basis, not just to do with fuels but to do with all
issues regarding a factory's performance, and also we distribute
newsletters and briefings to politicians and elected officials,
on a very regular basis. The technology of a cement kiln has significant
advantages; we do operate at extremely high temperatures, the
actual flame is in excess of 2,000 degrees Celsius, the materials
within the process reach temperatures of 1,450 Celsius, which
are significantly higher than those achieved in high temperature
incineration, and because we have a significant amount of limestone
in our process, it acts as a scrubbing agent, and a lot of the
potentially harmful elements are captured within that process
and come out as a product. And because the way we produce the
product is to form a glassy substance, it becomes vitrified, and,
as a result, any potentially contentious elements are actually
encapsulated; and there is no ash in our process, unlike incineration,
that have to dispose of the ash as a result of their process,
the ash forms part of the cement. So we think the fact that we
have high temperature breaking down any contentious hydrocarbons,
the fact that we have limestone scrubbing, we now have significant
levels of dust abatement in the back end of the process, we have
a long residence and we have no residue, means that, as an industry,
we are offering a very attractive solution. And we are not suggesting
that we are the total solution, if you read the Environment Agency's
paper, quoting six million tonnes of waste, we will not be able
to provide a total solution, but we can form a significant part
of the solution. And that is our proposition today; our proposition
is to revisit the Substitute Fuels Protocol and allow us to help
to be part of the solution.
Mr Lepper
405. Just one, very brief question. In Annex
III to your written submission, you tell us that the Substitute
Fuels Protocol "does not apply to any other industrial process."
Why does it apply only to your industry; that is one of the things
that puzzles me?
(Mr Gilbert) Well I think it started
here, which was a recommendation made during Select Committee
inquiries, that suggested that, as it was, at that time, a fairly
new science, and we were new to experimenting with these things,
there should be such a Protocol put in place to support the regulation
that existed and drive it forward. This is why really we are coming
back to this Committee today, to say, as part of your recommendations,
we hope you will say that the issues have moved on, the industry
has moved on, regulation has moved on, probably it is time to
revisit that Protocol.
Chairman
406. Can I ask just one technical question,
in conclusion. As far as you are concerned, the people who supply
you with waste of a high calorific value seem to get some benefits,
in terms of credits with reference to energy recovery; if the
same fuel is used by the high temperature incineration business,
they do not get the same benefit. Do you think there should be
inequality, effectively, should wastes disposed of by high temperature
solutions be deemed a recovery, or a disposal; do you think there
should be a difference between the cement and the high temperature
side?
(Mr Gilbert) I think we would say that, and with my
sustainable development hat on, it is probably better to use the
energy producing a product than just to use up the energy by burning.
So, I think, as an industry, we would certainly prefer that the
recovery of the energy is the higher step in the hierarchy.
(Mr Boarder) In fact, Mr Chairman, we have been concerned
about this question of definition for quite some time, and, in
fact, we went to the High Court for a judicial review on the subject,
and the judge found that the material was a waste until it was
burned, but was recovered, and the recovery process took place
at the cement kiln. So we feel we have got some justification
in saying we are definitely a recovery operation, not a waste
disposal operation.
407. I said it was the last question; there
is just one other point which has just occurred to me, again,
a point of clarification. When we visited the Cleanaway unit,
I gained the impression that, as far as waste disposal in a cement
kiln was concerned, if you had relatively low levels of material
going through one of your plants, you did not have to meet the
same emission standards which a specific high temperature incinerator
had to meet, but, as you increased the amounts going through,
and I am sorry I cannot be specific in terms of tonnages, but
perhaps you can help me, then the environmental demands made of
you, in terms particularly of final emissions, started to rise.
The first question is, is that factual? And, secondly, in terms
of your operation, where you are saying, I think Mr Davies used
the words, "We could be part of the solution, in terms of
disposal," is there a sort of cut-off point, at which you
will say, "We're quite happy to have this amount of material
coming through, but then, in investment terms, to go to higher
emissions standards, it doesn't become tenable;" really,
it is a repeat of my question about cherry-picking, are you looking
for the best deal for the cement industry, without having to go
over the top on environmental emissions control?
(Mr Gilbert) We comply with all the relevant regulations
and the Directives, the Directives do have differences in them,
but there is no inhibition on our industry, in terms of the ability
of the industry to perform to meet the emissions criteria, of
whatever volumes we began to use, were we able to speed up the
process by revising the Substitute Fuels Protocol. Dick, do you
want to touch on that?
(Mr Boarder) We comply completely with the Hazardous
Waste Incineration Directive; the Environment Agency insists we
do. Now there are clauses in there about co-incineration, and
we come under a co-incineration Clause; the Environment Agency
are very tough on us in the way they interpret that, and most
of the initial limits are the same as the incinerators.
408. Most, but not all?
(Mr Boarder) There are only one or two areas where
that is not the case.
409. I am going to ask, again, a technical question.
If it were to be the case that rules were put in place to say
you had to match, in every respect, that which the current high
temperature incineration plants have, is it technically feasible
for a cement plant to operate in those circumstances?
(Mr Boarder) One of the areas where there is a pro
rata, that you were talking about, is in terms of dust; and
you have to remember that our product is dust, so, a cement kiln
making a million tonnes a year of cement, we are processing million
of tonnes of dust a year, and that is limestone, clay, dried limestone,
dried clay minerals, and so it would seem unfair to limit us to
the same dust limits that we have for a high temperature incinerator
processing hazardous materials. Having said that, the new Waste
Incineration Directive, which overtakes the Hazardous Waste Directive,
does impose very, very strict, tight limits on dust for co-incineration,
which will require investment in our plants, quite a heavy investment,
and we, as an industry, accept that need to comply with those
regulations.
Chairman: Thank you very much, Mr Gilbert, Mr
Davies and Mr Boarder. You have had your opportunity on behalf
of the cement industry to have your say, and we are grateful for
the time and trouble you have taken to put your case to us. As
I said before, you cannot retract that which you have said, but
if there is anything else, in the next day, or so, that you feel
that you wanted to let us have, we will be happy to look at it
before we produce our report. Thank you very much for coming and
joining us.
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